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I find the revised plans offer little in the way of addressing the previous problems with the rejected previous plans as determined by the WLPP. The issues that are of concern are numerous and have only grown with the new DA for 28 George St. Where some small improvements have been replaced with new larger issues.

1. The applicant suggests they are 3 bedroom townhouses whilst the BASIX and cross section AA notes that infact there are four bedrooms. I will consider there are 4 bedrooms as per some of the plans. We all know the "study" listed in some of the plans is the 4th bedroom. Seems like a slip up to have noted it correctly as a 4th bedroom in some of the plans. Maybe the void can become the study?

2. The "void" is a paper thin accounting trick to comply and shows the ingenuous intent to build to the code. The developer has used 4 reasonably sized voids to avoid issues with FSR and BASIX. Upon being built, we all known the voids are opened up for use. Ask anyone in the industry. There is no design sense in having "voids" in key areas of the house and so large when otherwise the plans are for a build pushing to an inch all other limits. FSR and BASIX would fail with voids counted... which they should be.

3. The BASIX scraps through the 50 point requirement. Numbers entered in the BASIX seem to be wrong in some areas. They suggest a roof space of 458 sqm for water catchment. To fill the 800l water tanks. If each unit is roughly 70sqm per floor, even with eaves and the slight angle of the roof 458 sqm seems large. 4 x 70sqm = 280sqm + angle + small eaves. "void" not counted. Needs clarification.

4. They are lowering the natural and existing ground level in order to comply with the height limits. Otherwise the plan would push them above the limit. They are asking for a setback allowance at the front to accommodate the bulky design. I would say that lowering the verge this much for the basement driveway will make it a pedestrian hazard.

5. The plans are for a 3 storey building in a R2 zone. Since the garage is partially out of the ground at the front and would technically count as a floor. Three storeys are not allowed within the code DCP B1 5.2.2 Further analysis on rulings here needed.

6. Without rubbery numbers the FSR fails.
a: They have not counted the void in each unit which is ingenious.
b: The FSR calculations use a garage floor area 42.7sqm, they have allowed for 36sqm allowance of the garage, however this only leaves 6.7sqm which seems small for the rest of the level. Maybe there are more "allowances" here?
c: They have used all 3 levels floor space to get the large patio areas to comply to 25% of floor space. Without the basement, which I think woudl be unallowable in the code, this would not work. Have they counted the balconies?

7. The previous determination from the WPLL address the overall bulk of the design. We now have 3 storeys, lowering of ground level and still the plans are close to height limit. The FSR suggested to be just under 50% is similar the last plan. So the overall bulk has not been addressed, and has in fact increased considering the extra storey. Neighbours should be concerned for their loss of natural light, privacy and where the previous plan had a driveway on one side the building is now closer to them. i.e it's wider.

8. The previous determination from the WPLL asked the developer to address the character of the development to be consistent with the existing and future character. The new plans do nothing to address this. They mention vinyl cladding. Vinyl cladding is not in keeping with the area nor desirable. The roof is a slightly pitched skillion roof not reflecting the pitched roofs found in the area. The colour scheme is grey upon grey which a dreary modern trend and not in keeping with the village look and feel. As some other building materials are not specified exactly it is hard to comment further, except to say this maybe my only right of reply and I understand them to be modern and not reflecting the majority of the area. As mentioned in the developers EIS there are indeed a few modern examples in the street that aren't in keeping the area, however they should not be regarded as the benchmarks to aim for, but rather as lessons to not repeat.

9. The general amenity is not good for the proposed inhabitants. Having 12 or perhaps 16 bedrooms on the block is overdevelopment for the block. The rear garage has no turning circle and it would only be possible to reverse out, down the interior garage ramps past other driveways which would be dangerous. The visitors parking can not be a turning circle also. The BASIX is passed by massaging the numbers and adding possibly the smallest water tanks (800l) possible. Air Conditioner for winter and summer would be required as they all over shadow each other and the opening in the middle will not be a desirable space in constant shade. The overall design is not making use of the suns position making it both in-efficient and with poor amenity.

10. The area has many natural springs and massive amounts of under ground water passing this area. This is why there are 2 paperbark trees outside the property. Number 20 has water constantly weeping through their concrete driveway and the new development up the road where they dug a basement garage was constantly flooded during construction and has ongoing issues. There is underground water which is not accounted for. When they disrupt the under ground water the effects will be numerous and pose a threat to the paperbark trees and the neighbouring trees and properties. They need a geo-tech and arborist report into this accounting for the known issues and sub ground drainage plans that will satisfy not disrupting the natural landscape around them. The drainage report only seems to account for above ground water.

11. Many people are concerned about the extra traffic having 4 x 4 bedroom townhouses will bring. I understand they can't be personally responsible for the all traffic issues on George St and the area... however, they are building a multi unit development and driveway exactly opposite Kelton Lane. A lane which might seem insignificant, however offers the only route in and out of the area if (and when) the main exit is blocked. Most residents now use Kelton lane to go through to Pass ave to bypass traffic issues in the area. Kelton lane often has 3 cars facing off to work out right of way, so by adding a multi unit development directly across from the lane makes it a 4 ways for the future residents of 28. Kelton lane is an issue which needs to be addressed by planners with any multi unit development at number 28. They will also be entering from a higher angle which would add to the complexity for exiting with pedestrians. A footpath study was carried out by council and might be worth correlating its findings with this DA.

Overall I see no improvement to the design as small wins in some areas are replaced by other issues. The intent of the developer is to make money by building as much as possible on the block at the cost of amenity to the future inhabitants and local residents. Every measurement is pushed to the limit to make it comply by a whisker whilst I feel many of these numbers are rubbery or erroneous. I am not a developer, building or town planner, so please excuse any errors in my interpretation. It takes a lot of time for local residents to read plans and understand some the complexities of larger and demanding developments in R2. There are already 5 multi unit developments on George Street which satisfy low income housing, so there is not an argument that we need a mix of housing in the area. Nearer to transport, public space and on a larger block would be more appropriate for this design.

thanks
Jeremy

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